HIT/HIE Community and Organizational Panel Office of Health - - PowerPoint PPT Presentation

HIT/HIE Community and Organizational Panel

Office of Health Information Technology May 19, 2016

Welcome, Introductions, and Agenda Review

Agenda

• Roundtable: Brief updates, successes, and challenges

– Approach or current thinking about your fee model

• HealthTech Solutions: Fee Model Approaches in Health

Information Exchange

• OHA Fee Model Selection Process
• Interoperability Update

– Interoperability Pledge – CMS State Medicaid Director’s Letter – Measuring Interoperability RFI

• Behavioral Health HIT Scan
• OHA Behavioral Health Information Sharing Advisory

Group Update

3

Roundtable

• Brief updates
• Successes
• Challenges
• Next Steps
• Approach or current thinking about your fee model

4

FEE MODEL APPROACHES

IN HEALTH INFORMATION EXCHANGE

HealthTech Solutions, LLC.

May 19, 2016

Objectives

HealthTech Solutions, LLC.

Issues Addressed:

HIE Business Models Evolving Factors Fee Model Structure Lessons Learned

Market Structure

HealthTech Solutions, LLC.

 The blurring of private and public HIEs  Network of networks  Private HIEs (partial list)

 Integrated Delivery Networks (IDNs)  Vendor networks  Payers

 Public HIEs

 Community HIEs/HIOs  State HIEs

Historical Development: Locally Driven Solutions

 1990s: Clinical Health Information

Network (CHINs)

 2000s: Regional Health Information

Organizations (RHIOs)

HealthTech Solutions, LLC.

Problems

Governance Sustainability Absence of Standards Economic Incentives for Exchange De Facto Development

• f “Walled

Gardens”

Structural Considerations

HealthTech Solutions, LLC.

 Economies of Scale  Network Effects  Value Bundles & Scope of services

Models of State Funding

HealthTech Solutions, LLC.

 Cooperative Agreements

 HITECH Seed Money for HIEs  State-level allocation with limited ONC guidance

 Three principal approaches

Source: NORC EVALUATION OF THE STATE HIE COOPERATIVE AGREEMENT PROGRAM, Office of National Coordinator HIT

Third Party Funding

HealthTech Solutions, LLC.

 State line budget support  State mandated support by payers  Strong partners

 Payer (e.g., Michigan—MiHIN)  IDN (e.g., Pennsylvania—KeyHIE)

Governance Considerations

HealthTech Solutions, LLC.

 Varies by region  Medical trade area  Vast differences

“If you’ve seen

• ne HIE, you’ve

seen one HIE”

Technology Offerings Drive Value Propositions

HealthTech Solutions, LLC.

 Increased focus on technology enabling use cases

 ADTs  Provider Directories

 Shift to data element transmission from document

transmission

 Open API’s, Fast Healthcare Interoperability Resources (FHIR)

 SMART on FHIR is leading in application development  Developed from Harvard initiative

 Traction with HL-7 committees

HIE Service Offerings

HealthTech Solutions, LLC.  Agreement about the value of HIE as a whole is high however

agreement about the value of each specific service is not

 HIE service offerings are being delivered by all types of

• rganizations, throughout the healthcare ecosystem

 The following list of HIE services offered today is changing

• ften

HIE Service Offerings

HealthTech Solutions, LLC.

Direct Secure Messaging C-CDA Document Exchange Longitudinal Records

• Consolidated

sections

• More

searchable

Provider Directory Services

• From basic to

very advanced care routing

HIE Service Offerings

HealthTech Solutions, LLC.

Patient Attribution Services eMPI and Master Data Management Systems Event Notification Systems

• Rules-based

routing

• i.e. Admit

Discharge Transfers

• Medical Home

subscriptions

eCQM Repositories

HIE Service Offerings

HealthTech Solutions, LLC.

Medication History & Management Social program services availability Common Credentialing Public Health Gateways Medicaid member Personal Health Records Assessment repositories

Fee Model Approaches

HealthTech Solutions, LLC.

Subscription Membership Usage or Transaction Based Combinations Tiers in all

Subscription Model Structures

HealthTech Solutions, LLC.

 Multiple services to choose from  Each service has its own fee  Some of the services might be bundled  Example:

Cable Subscription Cable TV Internet Telephone

Membership Model Structures

HealthTech Solutions, LLC.

Very common due to where HIE is at in the maturity cycle Membership models help blend pricing for services that are new or still evolving rapidly

Where there are a number of services who’s value is still being tested Where there are services that may be challenged to stand on their own ability to be priced

Encourages usage of current and new function

New functionality that is added to existing bundles to add value can be tested without added fees No usage volume charge

Fee for being a part of or belonging to (similar to a golf membership) All or most of the services are bundled

Usage or Transaction Model Structure

HealthTech Solutions, LLC.

May be used for certain services or all Strictly by historical usage count times fee Seen in utility based environments (water, electric etc.) Typically seen as the fairest method by many participants Often has a base charge, even at zero activity Suited for very mature services with a more concrete value proposition

Types of Tiers in Practice

HealthTech Solutions, LLC.

 Tier by organizational attribute

 Hospital Fees – hospital size  Provider Practice Fees – provider count  LTC, Nursing, Assisted, SNF, etc. – number of beds

 Tier by transaction

 0-10,000 message  10k – 50k  50k – 250k

HealthTech Solutions, LLC.

Lessons Learned

Tiers unique to each

• rganization

type Best guess at adoption and verify with health care

• rganizations

Include their association

• rganizations

Plan to continually add new participant group types along the way

Incentives work Allow grouped pricing

Fees fair and transparent

What is Changing: Value Drivers

HealthTech Solutions, LLC.

Value-based models Critical mass of bundled services Technology

Questions??

Gary.Ozanich@healthtechsolutionsonline.com Kim.Norby@healthtechsolutionsonline.com

HealthTech Solutions, LLC.

Break

26

Health Information Technology Project Fee Development

Melissa Isavoran, Common Credentialing Lead

47

Fee Enabling Legislation

• House Bill (HB) 2294 from the 2015 Regular Legislative

Session gives OHA authority to set fees for users of CareAccord and Provider Directory services

• Senate Bill 604 from the 2013 Regular Legislative Session

gives OHA authority to set fees for practitioners and credentialing organizations mandated to use common credentialing; not to exceed the cost of administering

50

Current Funding

Transformation Funds: The Legislature awarded $30 million to CCOs to support their health system transformation efforts for state-level HIT efforts. With support of CCOs, OHA retained $3 million of the Transformation Funds to leverage federal funds for investing in statewide HIT infrastructure such as:

• Statewide Provider Directory
• Clinical Quality Metrics Registry

CMS MMIS OAPD-U Funding: Federal Fiscal Participation (FFP) in Medicaid Management Information Systems (MMIS) enhanced match for

• ngoing support under operations and maintenance:
• CareAccord

Common Credentialing will be a fee supported program.

51

Fee Establishment Processes

Fee Establishment Process

Fee development Charge fees Develop fee principles Develop fee structure Market research Identify costs Stakeholder initial input Legislative approval OHA internal reviews (Budget/Accounting) Rule development Federal funding updates (I-APD, O-APD) Finalize fee structure 52

Signifies opportunity for stakeholder input

Oregon Common Credentialing Program Fees

Melissa Isavoran, Lead

53

Current Credentialing Fee Structure

 Credentialing organizations generally cover the costs of

credentialing practitioners

 Practitioners generally do not pay for credentialing, BUT:

‒ Privileging is supported by fees and includes credentialing ‒ Some credentialing costs are built into provider payments ‒ Practitioners pay for office staff hours to complete credentialing paperwork and required follow up

54

Fee Establishment Processes

Common Credentialing Program: Fee Establishment Process

Fee development Charge fees

Fees to be charged

• nce fully operational

Mid 2017

Developed fee principles based on input and research Develop fee structure based on input and research; surveys Market research via Request for Information and vendor research Identify costs via proposals and final contract negotiations Stakeholder input from Advisory Group and subject matter experts Legislative approval Slated for 2017 Regular Session OHA internal reviews (Budget/Accounting) Continuous Rule development Second and third quarters of 2016 Federal funding updates (I-APD, O-APD) Finalize fee structure and establish fees via rules 55

OCCP Fee Structure Principles (at a high level)

Fees should be:

 Balanced considering benefits and resources  Efficient and economical to administer  Transparent and justifiable in development  Stable and produce predictable income to support the costs of

• perating common credentialing which should include

allocations for information technology and operational quality assurance activities and security

Individually requested processes must be borne by those making requests

56

OCCP Fee Structure Options

FEE OPTIONS STRUCTURE Credentialing Organizations One-Time Setup Fee Flat Fee Tiered fee Flat Fee, + Amortization Annual Subscription Fee Tiered fee (hospital revenue/practitioner panel size) Transactional Fee (ongoing operations and maintenance costs) Flat Fee Tiered Fee; based on Practitioner Type Expedited Credentialing Fee Flat fee per expedite request (each practitioner) Health Care Practitioners Initial Application Fee Flat fee (one-time) Tiered Fee; based on Practitioner Type Data Users Data Use Fee (Provider Directory) Undetermined

57

Next Steps for OCCP Fees

 Development of Credentialing Organization fee structure

tiers

 Rulemaking Advisory Committee (April 2016 – September

2016) ‒ Develop rules ‒ Submit Notice of Proposed Rules to Secretary of State ‒ Public rules hearing ‒ Publish final rules

 Legislative approval process (2017 Regular Session)  Fees to be charged once fully operational (mid 2017)

58

Interoperability Update

Interoperability Pledge CMS State Medicaid Director’s Letter Measuring Interoperability RFI

37

Interoperability Pledge

Susan Otter

38

Interoperability Pledge

90% of the companies that provide 90% of EHRs in use by hospitals nationwide, and the tope 5 largest health care systems have agreed to implement 3 core commitments (https://www.healthit.gov/commitment):

• Consumer Access: consumer can easily and securely access their

information electronically, direct it to a desired location, learn how its shared and used, and be assured that it is used safely and effectively

• No Blocking/Transparency: not knowingly or unreasonably

interfering with information sharing

• Standards: implement federally recognized, national interoperability

standards, policies, guidance, and practices for electronic health information, and adopt best practices including those related to privacy & security

39

Pledge Entities with an Oregon Footprint

• Allscripts
• Athenahealth
• Cerner
• eClinicalWorks
• Epic
• GE Healthcare
• Greenway Health
• Intel
• McKesson
• Meditech
• NextGen
• SureScripts
• Wellcentive
• Healthcare Systems:

– Catholic Health Initiatives – Kaiser Permanente – Trinity Health

• Associations

– AAFP, ACP, AMGA, AMIA, AMA, AHIMA, AHA, CHIME, HIMSS, etc.

• Other organizations:

– Commonwell – Sequoia Project

40

For a full list of entities that have taken the pledge, or to take the pledge, visit: https://www.healthit.gov/commitment

CMS State Medicaid Director Letter for HIE HITECH funds

Susan Otter

41

State Medicaid Directors Letter 16-003

CMS and ONC have partnered to update the guidance on how states may support HIE and interoperable systems to best support Medicaid providers in attesting to Meaningful Use Stages 2 and 3:

• Allows HITECH funds to support all Medicaid providers that EPs

want to coordinate with

• Funds can support HIE on-boarding** of Medicaid providers not

incentive-eligible including behavioral health, long-term care, home health, correctional health, substance use treatment providers, etc. as well as labs, pharmacy, and public health providers

• Possible activities include on-boarding to: a statewide provider

directory, care plan exchange (unidirectional or bidirectional), query exchange, encounter alerting systems, public health systems **On-boarding must connect the new Medicaid Provider to an EP and help that EP in meeting MU

42

State Medicaid Directors Letter 16-003

The basis for this update, per the HITECH statute, the 90/10 Federal/State matching funding for State Medicaid Agencies may be used for:

“Pursuing initiatives to encourage the adoption of certified EHR technology to promote health care quality and the exchange of health care information under this title, subject to applicable laws and regulations governing such exchange.”*

*http://www.hhs.gov/ocr/privacy/hipaa/understanding/coveredentities/hitechact.pdf

43

State Medicaid Directors Letter 16-003

How it works:

• Funding goes directly to the state Medicaid agency (IAPD)
• Funding is in place until 2021

– 90/10 Federal State match. State is responsible for providing 10%

• Funding is for HIE and interoperability only, not to provide EHRs
• Funding is for implementation only, not for operational costs
• All providers or systems supported by this funding must connect to

Medicaid EPs

• Medicaid systems must adhere to Medicaid Information Technology

Architecture (requires adherence to 7 conditions/standards, including Interoperability, Modularity, and Reporting)

44

OHA Approach to the SMD Letter

• Informal discussions have started internally and externally about

possibilities of the HIE funding for HIE onboarding of a wider array of providers and care team members

• Presented to CMS a high-level approach focusing on onboarding
• “Draft HIE Onboarding Concept”

– Support a network of networks; no one HIE solution – Pay the Medicaid portion of onboarding to an HIE of a provider’s choosing – Set up criteria for HIEs to be eligible to receive onboarding support – Focus on specific provider types and data that have had barriers to onboarding and/or not eligible for EHR incentives:

• behavioral health, dentists, labs, radiology, long-term care, social services,

corrections

45

Health Information Exchange Efforts in Oregon

• Regional HIEs
• Emergency Department Information Exchange
• Direct secure messaging within EHRs, between HIEs

– CareAccord, Oregon’s statewide HIE

• Vendor-driven solutions:

– Epic Care Everywhere, CommonWell

• Federal Network (the Sequoia Project)

– Connection to federal agencies: SSA, CMS, VA, etc.

• Other organizational efforts:

– by CCOs, health plans, health systems, independent physician associations, and others – Including private HIEs, point-to-point interfaces, HIT tools, hosted EHRs, etc. that support sharing information across users

Hospital Event Data – by County

CCOs (PreManage), Hospitals (EDIE)

Regional HIEs – by County

OHA Approach to the SMD Letter

• OHA’s next steps to build the concept:

– Socialize the initial “Draft HIE Onboarding Concept” – Draft an initial straw model for formal conversations with stakeholders, including HITAG and HITOC – Continual conversations with CMS – Stakeholder input – HITOC strategic planning process – Develop a formal strategy with stakeholders – Formal CMS approval of concept to seek funding

49

ONC’s Measuring Interoperability RFI

Marta Makarushka, Lead Analyst

50

Measuring Interoperability RFI

Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) requires that HHS establishes metrics to assess the achievement of widespread interoperability

• To assist with defining the scope of measurement, ONC is

soliciting feedback on the following:

– What populations and key components of interoperability should be measured? – What current data sources and potential metrics should be used to measure interoperable exchange and the use of exchanged information? – What other data sources and metrics should HHS consider to measure interoperability more broadly?

51

Measuring Interoperability RFI

Populations and Key Components

ONC intends to measure interoperable exchange and the use of information through four components (1) sending (transmission) (2) receiving (3) finding (query) (4) integrating received information into the patient record and (5) subsequent use of that information.

• Should the focus of measurement be limited to Meaningful EHR

Users (MUsers) and their exchange partners? Or include behavioral health, LTC, consumers per the Roadmap?

• Should measurement be limited to CEHRT?

52

Measuring Interoperability RFI

Available Data Sources and Potential Measures

ONC is considering two different data perspectives (1) measures of providers using EHRs, exchanging data, and re-using the data and (2) transaction measures Available data sources to ONC are (1) national survey data collected by stakeholders and federal agencies and (2) EHR Incentive Program Data

• Do survey data adequately address the exchange and use?
• Do national surveys provide the necessary information to

determine why electronic health information may not be widely exchanged?

53

Measuring Interoperability RFI

EHR Incentive Program Measures

CMS collects data for eligible professionals facilities under Medicare while the states collect data for those eligible under Medicaid. The methods and information are not the same. Also, the focus of the measures is on transmission of information and not on the consumption and use of the data.

• Do incentive program measures adequately address the

exchange component of interoperability?

• Do reconciliation activities (medication reconciliation) serve as

adequate proxies to measure subsequent use of exchanged information?

• If the data are limited to Medicare-only eligible providers would it

be valuable to develop new measures evaluating exchange and subsequent use of information?

54

Measuring Interoperability RFI

Other Data Sources

ONC is interested in other data sources including Medicare claims data, performance category measures for MIPS, electronically generated data such as server log audits, and surveys or data from entities that enable exchange such as HIEs..

• Should ONC use a single data source for consistency or data

from a variety of sources?

• What are the highest priority measures to include?
• What other national-level data sources should ONC consider?

Do technology developers, HIEs, HIOs, or other entities have suggestions for national level data

• How should “widespread” be measured?

55

Measuring Interoperability RFI

Your thoughts?

• What aspects/types of information exchange do you think

represent interoperability?

• What data do you collect that could be used as a measure
• f interoperability?
• How would you define ‘widespread’ interoperability?

56

Behavioral Health Provider HIT/HIE Survey

Marta Makarushka, Lead Analyst

57

Behavioral Health Provider Survey

Why conduct a behavioral health provider HIT/HIE survey?

• Coordinated Care Model relies on HIT infrastructure to share

data across provider types

• Limited types of behavioral health providers are eligible for the

EHR Incentive Program

– Lower rates of HIT adoption – Lack of data

• Survey will

– Provide information about adoption, barriers, plans, and priorities – Highlight areas of needed support for OHA to consider – Potentially inform policies

58

Behavioral Health Provider Survey

Questions to cover the following topic areas:

• EHR use
• Barriers to EHR adoption and use
• HIE participation
• Use of Direct secure messaging
• Providers with whom they exchange data
• Value of HIT/care coordination
• Future plans for HIT

59

Behavioral Health Provider Survey - Timeline

• Spring: survey planning, key stakeholder interviews
• Summer: release survey, data collection, follow-up
• Fall: data analyses, draft report, visuals

– October: HITOC to review draft report

• November: Final report released

Next Steps: Distribute draft survey and obtain feedback.

60

Behavioral Health Information Sharing Advisory Group Update

Veronica Guerra, Policy Lead

Overview of the Advisory Group

• Need: Lack of understanding of Part 2 and state laws

impacted CCOs’ care coordination ability

• Goal: To develop solutions to support integrated care

and enable sharing of behavioral health information between behavioral and physical health providers

• Members/Partners: Internal staff from across the

agency

62

Priorities:

• Outreach to stakeholders
• Education
• Leverage existing IT solutions
• Develop tools to facilitate information sharing

Advisory Group Update

• Subscribed to Actionline consultation services
• Conducted a third webinar on March 30th
• Submitted a response to SAMHSA’s 42 CFR Pt 2

Notice of Proposed Rulemaking on April 11th

• Developed a webpage with resources for

providers

• Began the development of a model Qualified

Service Organization Agreement (QSOA)

63

Webinars

• Webinar #1: September 29, 2015
• Topic: Overview of state and federal privacy laws
• Presenters: SAMSHA, the Legal Action Center, and the Oregon

Department of Justice

• Attendees: 300
• Webinar #2: December 17, 2015
• Topic: Deeper dive into federal privacy laws with use case examples from

providers

• Presenters: Robert Belfort, from Manatt, Phelps & Phillips, LLP
• Attendees: 275
• Webinar #3: March 30, 2016
• Topic: Oregon Health Information Technology and the Intersection with

Part 2

• Presenters: Susan Otter, OHA Office of Health Information Technology,

Gina Bianco, Jefferson HIE, and Lynne Shoemaker, OCHIN

64

OHA’s Next Steps

• Develop a model common consent form
• Revise Qualified Service Organization Agreement given

proposed Part 2 rules

• Continue to collaborate on Jefferson HIE ONC grant
• Continue development of a provider toolkit covering

privacy laws, case studies of allowable sharing, model forms, and FAQs

• Continue engaging federal partners in discussions

about modifications to Part 2

• Continue consulting with other states

65

66

For more information about the Behavioral Health Information Sharing Advisory Group and access to webinar recordings, please visit:

http://www.oregon.gov/oha/amh/Pages/bh-information.aspx

Resources

Process Check

• Are you finding these meetings valuable?

– Most valuable? Least valuable?

• What did you like about today’s meeting?

– Topics? – Format? – Discussion?

• What would you like to see us change?

– What should we add? – What should we remove?

67

Conclusions, Next Meeting, and Action Items

• HCOP to continue meeting quarterly in 2016

– July 12th 1-5 pm: Need to reschedule – October 14th 1-5 pm

68

For more information on Oregon’s HIT/HIE developments, please visit us at http://healthit.oregon.gov Susan Otter, Director of Health Information Technology Susan.Otter@state.or.us Marta Makarushka, Strategy and Policy Analyst Marta.M.Makarushka@state.or.us